It should be noted that while the disks do keep counters their space for such counters is small and you can sometimes over it and do some places are forgotten. I've seen it happen on HDDs and had this as a root cause of some repeated failures at some customers due to their specific workloads and their interaction with the system.

I do support you in the general point that this is rather unit to work on SSDs but it may work on HDDs as they have a similar failure mode and physical locality is easier to achieve there on them.

That said they unlikelihood didn't make it impossible. Filesystems should be written and tested against such attacks.